Protecting wild geese is one of the reasons Labour Minister Aodhan O Riordain is objecting to plans for 381 new homes in Dublin.

The plan to build the homes on green space beside Saint Anne's Park, Raheny could harm the migration patterns and habits of brent geese which spend winters on Bull Island, he said.

Developer Greg Kavanagh has lodged plans to build 107 houses and 274 apartments in five six-storey blocks on the site.

The 15-acre plot which is adjacent to St Paul's school on Sybill Hill Road was purchased from the Ventian religious order earlier this year.

The plans lodged with Dublin City Council include two all-weather sports facilities and it is expected that part of the developer contribution paid to DCC will be reinvested in St Anne's Park to improve playing facilities there.

A joint written submission of objection to the plan has been lodged by Minister O Riordain and his party colleague, Clontarf councillor Jane Horgan-Jones.

Residents

"These lands are an area of visual beauty and have a long-standing use for recreational and leisure purposes enjoyed by local residents and many from further afield," they said.

"Such a large housing development in this area is not in keeping with the zoning objective of the land for the overall plan for the area," the letter argues.

They said the Brent Geese have been shown to use this portion of land regularly during their winter migration period in Ireland.

According to the objection, a development of this size has the potential to displace them and negatively impact on the biosphere in the vicinity of Bull Island, which is specifically protected under the provisions of the Dublin City Development Plan, they stated.

They said the developer should be asked how he proposes to avoid displacing the geese.

The site is zoned as community and institutional resource land for education, recreation, community, green infrastructure and health as well as being "open for consideration" for residential development.

They claimed the application fails to provide the required 25pc of land reserved for open space or community facilities.

Mr O'Riordain and Ms Horgan-Jones also claimed local schools were not able to facilitate a large increase in the local population.